Lucas v. MGM Resorts International

1 | PAUL T. TRIMMER State Bar No. 9291 || [email protected] JACKSON LEWIS P.C.

3 || 300 S. Fourth Street, Suite 900 Las Vegas, Nevada 89101 | Tel: (702) 921-2460 Fax: (702) 921-2461 HOWARD SHAPIRO (pro hac forthcoming) || [email protected] RENE E. THORNE (pro hac forthcoming) | Rene. [email protected] JACKSON LEWIS P.C. g || 650 Poydras Street, Ste. 1900 New Orleans, LA 70130 | Tel: (504) 208-1755 .

10 || JUAN C. OBREGON (pro hac forthcoming) [email protected] | JACKSON LEWIS P.C.

950 17th Street, Ste. 2600 || Denver, CO 802202 Tel: (303) 892-0404 Attorneys for Defendants 14 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA EBONI D. LUCAS, JEREMY GOARD, | CHRISTOPHER MANLONGAT and SHAWNDREA STAFFORD, individually {| and on behalf of all others similarly situated, 19 CIVIL ACTION NO. 2:20-cv-01750-JAD-NJIK Plaintiffs, | ¥: STIPULATED BRIEFING SCHEDULE AND || MGM RESORTS INTERNATIONAL, SCHEDULING ORDER SUBMITTED FOR THE INTERNAL COMPENSATION DEFENDANTS’ MOTION TO DISMISS | COMMITTEE OF MGM RESORTS INTERNATIONAL, THE SPECIAL REVIEW REQUESTED | ADMINISTRATIVE COMMITTEE OF MGM RESORTS INTERNATIONAL, and || JOHN DOES 1-30 ECF No. 16 25 Defendants.

26 Defendants MGM Resorts International, The Internal Compensation Committee of MGM Resorts International, the Administrative Committee of MGM Resorts International, and John 2g || Does 1-30 (“Defendants”), and Plaintiffs, Eboni D. Lucas, Jeremy Goard, Christopher Manlongat -1- || and Shawndrea Stafford, individually and on behalf of all others similarly situated (“Plaintiffs”), || by and through their respective counsel, submit the following proposed briefing schedule in || connection with Defendants’ Motion to Dismiss for the Court’s review and approval.

4 On December 14, 2020, Plaintiffs provided Defendants with waivers of service of the || Amended Complaint, making Defendants’ Motion to Dismiss in this class action matter due on || February 12, 2021. Given the complexity of the case, the parties agreed to an extension of that deadline by three weeks, and request that the Court order the following briefing schedule: 7 , g PROPOSED SCHEDULE 9 1. March 5, 2021 — Defendant’s Motion to Dismiss; 10 2. April 5, 2021 — Plaintiffs’ Opposition; 11 3. April 26, 2021 — Defendants’ Reply Brief in Support of Motion to Dismiss.

12 4. Because the outcome of the Motion to Dismiss will have a substantial impact on the scope, time and expense of discovery, the Parties request that further proceedings, 13 including submission of the LR 26-1 Scheduling Order and discovery, be held in abeyance until the Court has ruled on the Motion to Dismiss.

15 Dated: December 29, 2020.

16 | 4/ Paul T. Trimmer /s/ Mark _K. Gyandoh Paul T. Trimmer (NV Bar #9291) Mark K. Gyandoh JACKSON LEWIS P.C. CAPOZZI ADLER, P.C.

18 □□ pour □□□ 900 312 Old Lancaster Road Be Merion Station, PA 19066 20 ORDER 21 Based on the parties' stipulation [ECF No. 16] and good cause appearing, the Court adopts this proposed briefing schedule for the forthcoming motion to dismiss. However, to | obtain a stay of discovery or discovery-related obligations and deadlines, the parties must || file a proper joint motion to stay with a memorandum of points and authorities. See Tradebay, LLC v. eBay, Inc., 278 F.R.D. 597, 601 (D. Nev. 2011) (“It is well-established that a party || seeking a stay of discovery carries the heavy burden of making a strong showing why discovery should be denied.”’); see also Local Rule IC 2-2(b) (‘For each type of relief requested or purpose Il of the document, a separate document must be filed and a separate event must be selected for that || document”); Local Rule 7-2(a) (“The motion must be supported by a memorandum of points and authorities”).

27 a U.S. District JudgeJenniferd/ Dorsey 28 Dated: December 29, 2020